February 6, 2016 

US Department of Transportation, Docket Operations 

West Building, Ground Floor, Room W12-140 

Washington, DC 20590 

Re: FAA Exemption Rulemaking Section 333 ofthe FA Reform Act and Part 11-14 C.F.R. & 45.22(b); 14 

C.F.R. Part 21; 14 C.F.R. 61.113(a) & (b) (2); 91.109; 119.121; 91.151(a); 91.203(a) & (b) 91.405(a); 

91.407(a) (1); 91.409(a) (2); 91.417(a) & (b) 

Dear Sir or Madam: 

I, Jeffery E. Cook, am requesting an exemption from the Federal Aviation Regulations ("FARs") listed 

below and pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained 

within 14 C.F.R. 11 so I may commercially operate a small ultra lightweight unmanned aircraft system 

ruAS"), specifically the DJI Phantom Ill Professional and the DJIInspire 1 Professional or the equivalent 

and crew for the purpose of photography and videography of commercial and residential properties. 

I have been a UAS hobbyist for over three years without incident. I am applying for this exemption to 

allow me to legally perform aerial photography and videography contract work for real estate agencies, 

private individuals, photography and video organizations, and any other entity that may desire aerial 

photography and videography. As an informed hobbyist, I understand the importance of pre-flight, inflight, and post-flight safety measures to ensure the public and my safety. 

A grant of my exemption request by the FAA would permit operations of the specified UAS in 

predetermined areas away from the general public, airports, heliports, and vehicular traffic; primarily 

over individual properties and communities for the purpose of recording real estate listings. All flights 

shall be logged and recorded to minimally include the date and time of the flight, name of the pilot, 

visual observer, address or location of the flight, duration of the flight, weather conditions, and any 

other pertinent flight notes to include the altitude and speed along with signatures of the pilot and 

observer. A copy of the images recorded shall be retained for a minimum of 12 months form the date of 

the flight. 

In summary and in accordance with this request of exemption as authorized and outlined by the FAA 

under section 333{c) of the Reform Act specified for the use of UAS for "Real Estate" purposes, I Jeffery 

E. Cook will adhere to all FAA regulations at all times and shall conduct all flight operations in strict 

compliance of all safety protocols as mandated and required by regulations and best practices. I request 

the grant of exemption to operate the above specified UAS for commercial purposes as described in this 

request and allowable by law. This grant of exemption will allow me to offer my services to real estate 

professionals, private individuals, and any other organization requiring aerial photography and 

videography who do not have the required knowledge, experience, or certification to operate a UAS 

safely and in compliance with FAA regulations. The essence of this application is that I, Jeffery E. Cook, 

meet and exceed the FAA's expected competency for piloting UAS for commercial purposes and that my 

UAS meets and exceeds the safety requirements set forth by the Secretary of Transportation thereby 

prompting my request for COA under Section 333. 
1. Contact Information: 

Jeffery E. Cook 

242 Charleston Court 

Fort Mill, S.C. 29707 

704-219-4346 

jeff@ jeffcookphotos.com 

2. The specific sections of 14 C.F.R. I seek exemption from are 

- 14 CFR 21; 

- 14 C.F.R. 45.23(b) 

- 14 CFR 61.113 (a) & (b) 

- 14 C.F .R. 91, et seq; 

- 14 CFR 407 (a) & (1) 

- 14 CFR 409 (a) (2) and, 

- 14 CFR 417 (a) & (b) 

3. The extent and reason of relief I seek: 

1, Jeffery E. Cook, am seeking relief from existing FAR's that currently prohibit my use of UASs from 

operating commercially for the purpose of aerial photography and videography in accordance with the 

FAA Modernization and Reform Act of 1012-112 P.L. 95 & 331-334. 

Accordingly, all flights will be conducted with a Pilot In Charge and Visual Observer in accordance with 

FM Policy N 8900.227 Section 14 "Operational Requirements for UAS's" and with the following 

restrictions: 

a. All aircraft will be made with a UA Gross weight of less than 55 pounds. My exemptions request is for 

an aircraft with a weight less than 5 pounds. 

b. All flights will occur only during daylight hours. 

c. All flights will occur at or below 400 feet AGI. 

d. 5 nautical miles from an airport having an operational control tower; 

e. 3 nautical miles from an airport with a published instrument flight procedure but not an operational 

tower; 

f. 2 nautical miles from an airport without a published instrument flight procedure or operational 

tower; or 

g. 2 nautical miles from a heliport with a published instrument procedure. 

h. For safety, no flight with winds over 10 miles per hour 

i. Flight only in GPS mode which allows UAS to hover in place when radio controls are released. 
4. How my request will benefit the public as a whole: 

Aerial photography is a critical component of marketing commercially available property. With today's 

high tech internet market and ever demanding consumer, it is more important than ever for realtors to 

stay ahead of the curve by utilizing any and all available technology to grab the attention of the 

potential buyer. The use of UAS for these photography and videography services is much safer and more 

cost effective than attempting to capture these photos and videos via manned aircraft. Further, there 

are not enough certified UAS pilots to cover the growing demand for these photos and videos, which 

ultimately results in untrained/unqualified operators and increased risks due to lack of safety 

knowledge. 

5. Reasons why the exemption would not adversely affect safety; or how the exemption would provide 

a level for safety at least equal to the existing rule: 

An exemption would not adversely affect the safety because this application applies only to aircraft 

characteristics and applications within FAA specified limitations. These limitations provide for at least an 

equivalent safety standard. My past experience with UAS as a hobbyist allows me to utilize this 

experience in UAS operations thereby exceeding safety and improving airspace operations by allowing 

aerial imaging clients to choose and experienced operator that has the knowledge and skills necessary 

to pilot an aircraft safely and within regulated limits. In addition, by providing unmanned services to the 

market place, there will be less of a demand for manned operations, which will provide for safer and 

quieter residential photography and videography. 

6. In Summary 

I, Jeffery E. Cook, request that the FAA grant my exemption request and further volunteer any 

information gathered during flights in the event the FAA is interested in live field data. I do agree to 

attest to adhere to any further limitations the FAA imposes, now or in the future. Satisfaction of the 

current criteria provided in Section 333 of the Reform Act of 1012- size, weight, speed, operating 

capabilities, proximity to airports and populated areas and operation within visual line of sight and 

national security provide more than adequate justification for the grant of the requested exemptions 

allowing commercial operation of my UAS for commercial purposes. I look forward to supporting the 

FAA and UAS community in the quest to establish proper regulations and protocols for the safe 

introduction of unmanned aircraft into the national airspace. 

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